DCT
2:25-cv-01123
Modena Navigation LLC v. Mazda Motor Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modena Navigation LLC (Texas)
- Defendant: Mazda Motor Corporation (Japan)
- Plaintiff’s Counsel: Rubino IP
- Case Identification: 2:25-cv-01123, E.D. Tex., 11/14/2025
- Venue Allegations: Venue is alleged to be proper because the defendant is not a resident of the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s in-vehicle infotainment systems infringe four patents related to navigation display technology, including automatic day/night mode switching, dynamic map orientation, route modification displays, and the presentation of location-based activity information.
- Technical Context: The technology at issue resides in automotive navigation and infotainment systems, a key feature in modern vehicles for which user experience and interface design are significant market differentiators.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history involving the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-18 | U.S. Patent No. 7,385,881 Priority Date |
| 2006-10-13 | U.S. Patent No. 7,966,124 Priority Date |
| 2008-04-14 | U.S. Patent No. 8,131,461 Priority Date |
| 2008-06-10 | U.S. Patent No. 7,385,881 Issued |
| 2009-10-16 | U.S. Patent No. 8,423,286 Priority Date |
| 2011-06-21 | U.S. Patent No. 7,966,124 Issued |
| 2012-03-06 | U.S. Patent No. 8,131,461 Issued |
| 2013-04-16 | U.S. Patent No. 8,423,286 Issued |
| 2020 (approx.) | Start of Accused Product Model Years (2020-2026) |
| 2025-11-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,385,881 - Display Mode Control Method for an Electronic Device (issued June 10, 2008)
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience and potential distraction for a vehicle driver of manually switching a navigation device's display between a daytime mode and a nighttime mode (’881 Patent, col. 1:35-38).
- The Patented Solution: The invention provides an automated method for an electronic device to determine the time of day and switch its display panel accordingly. It operates in a "nighttime display mode," showing information in a light shade against a dark background, when the time corresponds to nighttime, and a "daytime display mode," with a dark shade against a light background, at all other times (’881 Patent, Abstract; col. 2:46-52).
- Technical Importance: This automation was designed to enhance driver safety and convenience by reducing screen glare during night driving without requiring manual intervention (’881 Patent, col. 1:29-34).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶22).
- Claim 1 requires a method comprising the steps of:
- enabling the electronic device to determine the time of day; and
- enabling the electronic device to operate the display panel in a nighttime display mode when the time of day corresponds to nighttime, and in a daytime display mode when the time of day is otherwise;
- wherein the navigational map information is shown on the display panel in a light shade against a dark background when the display panel is operated in the nighttime display mode, and in a dark shade against a light background when the display panel is operated in the daytime display mode.
- The complaint alleges infringement of "one or more claims," thereby reserving the right to assert additional claims (Compl. ¶21).
U.S. Patent No. 7,966,124 - Navigation Device and its Navigation Method for Displaying Navigation Information According to Travelling Direction (issued June 21, 2011)
The Invention Explained
- Problem Addressed: Conventional navigation systems often display the user's current position at the center of the screen. This can be inefficient, as half the display shows the already-traveled route, limiting the view of the path ahead and potentially causing a driver to miss upcoming turns or points of interest (’124 Patent, col. 2:20-34).
- The Patented Solution: The invention describes a method to dynamically adjust the on-screen display based on the user's direction of travel. It shifts the displayed current position away from the center to allocate more screen space to the upcoming route and dynamically adjusts the corresponding map view and scale (’124 Patent, Abstract; col. 5:46-6:17). This relationship is described as a "reverse relation" for the position and a "positive relation" for the map section (’124 Patent, col. 5:51-57).
- Technical Importance: This approach aims to provide the user with more relevant visual information about the path ahead, improving situational awareness and reducing the need to manually pan or zoom the map display (’124 Patent, col. 2:41-49).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶35).
- Claim 1 requires a method comprising the steps of:
- receiving a positioning signal to determine a current position and a direction parameter;
- generating a navigation route to a destination;
- initializing a "first displaying parameter" for the current position and a "second displaying parameter" for the navigation map;
- dynamically adjusting the first displaying parameter based on the direction parameter;
- dynamically adjusting the second displaying parameter based on the first displaying parameter; and
- displaying the current position and corresponding map section according to the adjusted parameters.
- The complaint alleges infringement of "one or more claims," reserving the right to assert additional claims (Compl. ¶34).
U.S. Patent No. 8,131,461 - Navigation Methods and Systems (issued March 6, 2012)
- Technology Synopsis: The patent discloses a method to assist with destination recognition. When a "navigation condition" occurs, such as the navigation process terminating upon arrival, the system displays a "position schematic diagram" that includes the destination and the user's current position to help orient the user when the detailed map view is no longer guiding them (’461 Patent, Abstract; col. 1:28-34).
- Asserted Claims: The complaint asserts at least Claim 7 (Compl. ¶47).
- Accused Features: The complaint accuses the functionality within Mazda's navigation system for modifying a route, such as adding a waypoint, which it alleges constitutes a "navigation condition" that triggers the display of a diagram showing the destination and current position (Compl. ¶48). The complaint provides a screenshot from an owner's manual depicting options to create a "New Route" or "Add to Current Route" after selecting a new location (Compl. p. 21).
U.S. Patent No. 8,423,286 - Method for Displaying Activity Information on a Navigation device and Related Navigation Device (issued April 16, 2013)
- Technology Synopsis: The patent describes a method for displaying location-based "activity information" (e.g., points of interest, events) on a navigation map. The method involves receiving activity data, providing an "information preference menu" to filter the data, displaying icons for the activities at their corresponding map locations, and providing a reminder message when the user approaches an activity location (’286 Patent, Abstract).
- Asserted Claims: The complaint asserts at least Claim 1 (Compl. ¶59).
- Accused Features: Infringement allegations target the MyMazda App Map, which allows users to display icons for points of interest such as dealers, fuel stations, and favorites on a map, and which provides reminder functionality (Compl. ¶60-61). A screenshot from a Mazda manual shows the "MyMazda APP MAP" interface with a shortcut menu for these categories (Compl. p. 26).
III. The Accused Instrumentality
- Product Identification: The accused instrumentalities are Mazda vehicles from model years 2020-2026, including their infotainment and navigation components, specifically "Mazda Connect" and "Mazda Connected Services" (Compl. ¶12-13). The 2025 Mazda 3 and 2025 CX-90-PHEV are identified as exemplary products (Compl. ¶21, 46, 58).
- Functionality and Market Context: The accused products provide integrated in-vehicle navigation and connectivity. The complaint alleges that these systems perform functions corresponding to the patents-in-suit, including: automatically switching the display between day and night modes (Compl. ¶23); displaying a navigation map oriented to the vehicle's position and route (Compl. ¶36); allowing users to modify routes by adding waypoints (Compl. ¶48); and displaying filterable points of interest on a map via a connected application (Compl. ¶60-61). Defendant Mazda is described as a major automobile manufacturer and seller in the United States (Compl. ¶2).
IV. Analysis of Infringement Allegations
'881 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) enabling the electronic device to determine the time of day | The system determines time of day via an internal clock, light sensors, or headlight system. | ¶23 | col. 3:5-6 |
| b) enabling the electronic device to operate the display panel in a nighttime display mode when the time of day corresponds to nighttime, and in a daytime display mode when the time of day is otherwise | The system automatically operates the display in distinct daytime and nighttime modes. A screenshot shows a "Day/Night Mode" setting on "Automatic" (Compl. p. 7). | ¶23 | col. 3:7-10 |
| wherein the navigational map information is shown on the display panel in a light shade against a dark background when the display panel is operated in the nighttime display mode, and in a dark shade against a light background when the display panel is operated in the daytime display mode | The navigation map is displayed with a dark background in night mode and a light background in day mode, as shown in screenshots of the system in operation (Compl. p. 8). | ¶23 | col. 4:23-31 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges the "time of day" is determined by an "internal clock, light sensors, or headlight system" (Compl. ¶23). The patent's sole embodiment, however, describes a "clock circuit" and user-configurable start and end times (’881 Patent, col. 2:59-62; col. 4:36-42). This raises the question of whether a determination based on ambient light from a sensor, rather than a clock-defined time period, falls within the scope of the claim term "time of day."
- Technical Questions: What is the precise trigger for the accused system's "Automatic" mode? The complaint's evidence does not definitively establish whether the system relies on a clock-based schedule (as described in the patent's embodiment) or solely on ambient light levels.
'124 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving at least one positioning signal ... and retrieving a current position ... for determining a direction parameter according the traveling direction of the navigation device | The system receives positioning signals (e.g., GPS) to determine the vehicle's current position and direction of travel. | ¶36 | col. 7:18-24 |
| initializing the current position and the navigation map to generate a first displaying parameter of the current position and a second displaying parameter of the navigation map | The system generates a map display focused on the vehicle's position ("first displaying parameter") and provides secondary information like turning directions in a corner of the display ("second displaying parameter"). | ¶36 | col. 7:29-34 |
| dynamically adjusting the first displaying parameter of the current position according to the direction parameter | The system refreshes the map to reflect the new vehicle position in relation to points of interest and upcoming turns. A screenshot from an owner's manual shows a "Turn preview and Next street" feature (Compl. p. 15). | ¶36 | col. 7:35-37 |
| dynamically adjusting the second displaying parameter of the navigation map according to the first displaying parameter | As the main map view updates, the secondary display elements (e.g., turning directions) are also adjusted. | ¶36 | col. 7:38-40 |
- Identified Points of Contention:
- Scope Questions: The patent describes the "first displaying parameter" as the pixel coordinate of the current position, which is dynamically shifted off-center to show more of the route ahead (’124 Patent, col. 5:29-32, col. 8:1-13). Does the accused system's "map focused on the current position" (Compl. ¶36) perform this specific off-center shifting, or does it simply maintain a centered view that updates with movement?
- Technical Questions: The complaint's allegations are described at a high level of functionality. A key technical question is whether the accused system's software architecture includes distinct, dynamically adjusted "first" and "second" displaying parameters that operate in the manner claimed, particularly the "reverse relation" between travel direction and the on-screen icon position.
V. Key Claim Terms for Construction
'881 Patent, Claim 1
- The Term: "time of day"
- Context and Importance: The infringement analysis depends on how the accused system "determine[s] the time of day." The complaint's assertion that this can be done via light sensors or a headlight system (Compl. ¶23) suggests a broad interpretation. The definition will determine whether systems triggered by ambient light, rather than a specific time on a clock, can infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the claim term is not explicitly limited to a clock.
- Evidence for a Narrower Interpretation: The specification's only described embodiment relies on a "clock circuit 16" (’881 Patent, col. 2:59-62) and a graphical user interface for setting specific "start and end times" for the nighttime period (’881 Patent, col. 4:36-42), which may support an interpretation tied to a clock-based schedule.
'124 Patent, Claim 1
- The Term: "first displaying parameter of the current position"
- Context and Importance: This term is the subject of the key "dynamically adjusting" step. Its construction is critical to determining whether the accused system performs the claimed invention. Practitioners may focus on this term because the patent's novelty appears to lie in shifting the vehicle's on-screen icon away from the center, not merely updating its location on a static, centered map.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint uses general phrasing like "a map focused on the current position" (Compl. ¶36), which could be argued to cover any view that updates with the vehicle's location.
- Evidence for a Narrower Interpretation: The specification defines this parameter as a "pixel coordinate for the current position to be displayed on the navigation information frame" (’124 Patent, col. 5:29-32) and explains that this coordinate is moved to a non-central location (e.g., the lower 35% of the screen) to show more of the road ahead (’124 Patent, col. 8:1-13, Fig. 4A). This suggests a specific technical meaning tied to the icon's on-screen placement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents-in-suit. Inducement is primarily based on allegations that Defendant provides customers with owner's manuals and other instructional materials that direct users to operate the accused systems in an infringing manner (Compl. ¶27, 39, 51, 64).
- Willful Infringement: Willfulness is alleged based on Defendant's knowledge of its infringement from at least the filing date of the complaint. In the alternative, the complaint alleges pre-suit willful blindness, asserting on information and belief that Defendant has a policy of not reviewing patents of others to avoid knowledge of its infringement (Compl. ¶26, 38, 50, 63).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: For the ’881 patent, can the term "time of day," which is described in the patent's embodiment as a clock-based schedule, be construed broadly enough to encompass a system that determines display mode changes based on ambient light levels?
- A key evidentiary question will be one of functional operation: For the ’124 patent, does the accused Mazda Connect system perform the specific, off-center shifting of the vehicle's on-screen icon as required by the claim's "first displaying parameter," or is there a fundamental mismatch in its technical method of displaying the map?
- A central challenge for the plaintiff will be evidentiary proof: The complaint relies on public-facing documents and high-level functional descriptions. The case may turn on whether discovery of the accused systems' source code and internal design specifications provides concrete evidence that the software operates in the specific, multi-step manner required by each of the asserted claims.